This section is from the book "American Law Of Real Estate Agency", by William Slee Walker. Also available from Amazon: American law of real estate agency.
In an action by a broker against his principal for a commission on an alleged sale of land made by plaintiff for defendant, the latter is not entitled to file an answer in the nature of a bill of interpleader by alleging that another broker also claims commissions for making the sale. Hurtsook v. Chriss-man, 114 Mo. App. 558, 90 S. W. 116.
A bill of interpleader will not lie at the suit of the seller to require two real estate agents to interplead as to which should have commissions on a sale of land, since, if either of them was entitled to commissions, it is because of some contract he had with the seller, and not because of anything that has happened between themselves. Sachsel v. Farrar, 35 I11. App. 277.
Where plaintiffs sue defendant for a broker's commissions for the sale of certain land made through their agency, the action by a third person against defendant, in another suit, to recover for work, labor and services in the sale of the land, is not a demand against him for the same debt within the Code of Civil Procedure, Section 820, allowing an order of interpleader when competent creditors demand the same debt. Taylor v. Satterth-waite, 22 N. Y. S. 187, 2 Misc. 441.
 
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